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Welcome to the MSL Blog!  A resource that offers guidance and thought leadership on issues to help your organization navigate the financial landscape in an ever-changing environment


MSL Pulse January 2018



We’d like to wish all of our readers a safe and prosperous 2018! Right out the gate, long-term care providers are facing significant challenges that will impact the entire industry for years to come. Legislative session begins early with several issues on the table including Certificate of Need (CON), Emergency Preparedness (Generator Rule) legislation, the implementation of the Prospective Payment System (PPS) for Medicaid reimbursement, and the Florida Constitution Revision Committee (CRC) proposals to essentially role back many of the torte reforms achieved in 2014 and impose additional insurance requirements on providers. And all of these issues are at the State Level in the middle of an election year, not to mention the myriad of changes coming from the Feds. Serenity now, serenity now.

Hurricane Tax Credit Available

 If you are an employer paying federal income taxes forced to close your business during Hurricane Irma and you kept your employees on the payroll during the close down period, you may get a credit against your federal income tax. Consequent to the recent natural disasters, Congress enacted the Disaster Tax Relief and Airport and Airway Extension Act of 2017, Public Law 115-63, which provides a tax relief for victims of Hurricanes Harvey, Irma, and Maria in the form of a tax credit against the taxpayer's income tax. In general, the credit is calculated based on 40 percent of wages, not exceeding $6,000 per employee during the closure period, paid or accrued on any day after September 4, 2017 until the earlier of (1) the date the business resumed significant operations or (2) December 31, 2017. Owners, shareholders, and partners are not included on the tax relief. Shareholders and Partners of S Corps and partnerships are entitled to the employee retention credit based on their respective distributive share for the tax credit. 

Most, if not all, of Florida was affected by Hurricane Irma and many of you had to close operations for a period of time in preparation, during, and after the storm. If you were a qualified employer per the above references, you may be entitled to the employee retention credit. For calculation of the credit, and the way to claim your credit, please consult your tax accountant.

Medicare Premiums and Deductibles for 2018

The CMS recently released the Medicare Part A and Part B premiums and deductibles for the calendar year 2018.  The Notices indicate that the daily coinsurance for days 21-100 in a skilled nursing facility will increase to $167.50 in 2018, an increase of $3.00 per day compared to 2017.  CMS announced the standard Medicare Part B monthly premium will increase from $109.00 in 2017 to $134.00.  The MMA requires beneficiaries with higher incomes to pay a higher percentage of costs for Medicare Part B, so, depending on their income level and tax status, these beneficiaries will see monthly premiums ranging from $134.00 to $428.60. Annual deductibles for most people will remain at $183.00.

CJR Pulled Back

At the end of November 2017, CMS announced a final rule and interim final rule with comment period which finalizes the cancellation of the Episode Payment Models (EPMs) and the Cardiac Rehabilitation (CR) Incentive Payment Model that were to begin on January 1, 2018 and implements changes to the Comprehensive Care for Joint Replacement (CJR) Model. 

Specifically, CMS is cancelling the Episode Payment Models (EPMs) and the CR Incentive Payment Model established by the Center for Medicare and Medicaid Innovation (Innovation Center. This rule makes participation voluntary for all eligible hospitals in approximately half of the geographic areas selected for participation in the Innovation Center’s CJR Model (33 of the 67 Metropolitan Statistical Areas (MSAs) selected) and for low volume and rural hospitals in all of the geographic areas selected for CJR participation. The list of participant hospitals still includes many in Florida so skilled nursing providers should take note. 

The CMS will hold a one-time participation election period for hospitals located in the voluntary participation MSAs and for specified low-volume hospitals and rural hospitals in the mandatory participation MSAs that begins January 1, 2018, and ends January 31, 2018. In order for a hospital to voluntarily continue to participate in the CJR Model, CMS must receive the hospital’s voluntary participation election letter no later than January 31, 2018. The hospital’s participation election letter will serve as the model participation agreement. For those hospitals that elect voluntary participation, the participation agreement will be effective February 1, 2018, and will continue through the end of the CJR Model.